"In preparing this report we note that there may have been expectations within the community that the program would be implemented quickly and that offers of compensation might have commenced by now," said the report.

"In practice, the establishment of the program framework is materially more complex than previous remediation programs conducted by the bank," it said.

The scale and size of the OAR program sets it apart from previous advice remediation programs, added Promontory.

"Given that the program has yet to complete formal assessment of customer cases, this initial report contains no findings in relation to sampling of customer case files," it said.

Instead, the report contains a summary of the measures taken by CBA to design and implement the program, including a 'pilot program' to test the assessment methodologies that will apply under the OAR.

The report reveals that CBA is employing 250 full-time staff to oversee the OAR, of which 75 per cent are employees or contractors of CBA.

As of 15 December 2014, the total number of cases in the OAR program was 4,702.

This includes 92 cases identified by CBA as having elected to opt out of the program, leaving the total at 4,610.

Plaintiff law firms Maurice Blackburn, Shine Lawyers, and Slater and Gordon have been appointed by CBA as independent customer advocates.